1. INTRODUCTION

We are Liberty International Ltd, Trading as 'Tenant Passport' in the UK, Rent Passport for all other Global Markets and 'The Rent Reporting Association' (“Us/We”), company registration number 14236527.

Please read this Privacy Policy carefully. By using any of the services that are set out in our Terms and Conditions You agree to be bound by this Privacy Policy. If You are providing us with another person's information You should first ask them to read this Privacy Policy and Terms and Conditions. By giving Us information about another person You are confirming that they have given You consent to provide the information to Us and that they understand how their details will be used.

Our website contains links to third party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.

We are committed to safeguarding the privacy of our website visitors; this policy sets out how We will treat your personal information.

This policy explains the information We collect, how We collect it and for which purposes. By using the website and the services We provide you are agreeing to be bound by this policy in respect of information collected about You through this site.

If you do not agree with this policy, please do not use this website or associated services.

 

 

2. INFORMATION WE MAY COLLECT

 

It is important that the personal data We hold about you is accurate and current. Please keep Us informed if your personal data changes during your relationship with Us.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which We have grouped together follows:

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• Identity Data includes first name, maiden name, last name, user reference, title, password and date of birth.

• Contact Data includes billing address, home address, email address and mobile telephone number.

• Tenancy Data includes passwords, tenancy start date, contract Length, number of tenants named on the contract, rent information, benefits you want from joining Liberty International Ltd (Mortgages, Credit Cards, Loans, Credit History Building, Other), landlord or agent identity and contact data.

• Financial Data includes bank account and payment card details.

• Transaction Data includes (a) details about payments to and from you and other details of products and services you have purchased from us; and (b) details about payments you have made to landlords/agents (c) details of transactions to and from your bank account from bank account reading.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, referral source, length of visit and number of page views for system administration. This is statistical data about our users’ browsing activity and patterns and does not identify any individual.

• Profile Data includes your email and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how You use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

If you fail to provide personal data

Where We need to collect personal data by law, or under the terms of a contract We have with You and You fail to provide that data when requested, we may not be able to perform the contract We have or are trying to enter into with You (for example, to provide You with goods or services). In this case, we may have to cancel a product or service You have with us but We will notify You if this is the case at the time.

 

3. HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE

Use of personal information under UK and EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your information:

• Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);

• Contract performance: where your information is necessary to enter into or perform our contract with you;

• Legal obligation: where we need to use your information to comply with our legal obligations;

• Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and

• Legal claims: where your information if necessary for us to defend, prosecute or make a claim against you or a third party.

 

We use information held about you (and information about others that you have provided us with) in the following ways:

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, Transactional and Profile Data to form a view on what we think You may want or need, or what may be of interest to You. This is how We decide which products, services and offers may be relevant for You (We call this marketing).

You will receive marketing communications from Us if you have requested information from us or purchased goods or services from Us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes.

Opting out

You can ask Us or third parties to stop sending You marketing messages at any time by contacting Us on rentbureau.info@gmail.com

 

 

4. DISCLOSURE OF YOUR INFORMATION

We may also disclose your personal information to third parties in the following circumstances:

1. We may disclose your personal information to our service providers and business partners, including payments processors, database tool providers and insurance providers (to assist us in performing any contract we enter into with them or you, including providing the Website and the Services it enables), analytics providers,  (to assist us in the improvement and optimisation of the Website) and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

 

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5. SHARING OF INFORMATION WITH CREDIT REFERENCING AGENCIES (referred to as ‘CRA’s)

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Not only will we be able to work with you more closely to manage your existing tenancy agreement, but your track record as a tenant will also enable the CRA's to use the information supplied to them to assist other landlords and organisations to:

• assess and manage any new tenancy agreements you may enter into;

• assess your financial standing to provide you with suitable products and services;

• manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;

• contact you in relation to any accounts you may have and recovering debts that you may owe;

• verifying your identity, age and address, to help other organisations make decisions about the services they offer;

• help to prevent crime, fraud and money laundering;

• screen marketing offers to make sure they are appropriate to your circumstances;

• for the CRA's to undertake statistical analysis, analytics and profiling,

• and for the CRA's to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.

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By signing up to Liberty International Ltd or by signing the short term tenancy agreement or by using our website, you acknowledge and accept that information regarding your rental payments and track record as a tenant or Landlord will be shared with Experian, Equifax and TransUnion, which will add this information to the credit reference data it holds about you and use it as a controller, in accordance with their privacy notices (a copy of which can be found by following the links below).
If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided in the following links: www.experian.co.uk/crain or  www.equifax.co.uk/crain or https://www.transunion.co.uk/legal/privacy-centre (Credit Reference Agency Information Notice (CRAIN)), (Credit Reference Agency Information Notice (CRAIN)). (For a paper copy, please get in touch with us or with the relevant CRA using the contact details in this letter).

We and the CRA's will ensure that your information is treated in accordance with UK data protection law. If you would like advice on how to improve your credit history you can access independent and impartial advice from www.moneyadviceservice.org.uk (you can get a copy of your Statutory Credit Report by visiting www.experian.co.uk/consumer/statutory-report).  

Please be aware that Experian may continue to hold and use Your information following any termination of your Liberty International Ltd services.
 

We also share your personal information with third party payment processor Stripe and/or Wix or third-party payment processors. Payments which manage payment of rent, splitting bills between tenants and facilitates a pay-as-you-go service for Renters. Further information in relation can be found in our terms of service.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in "Purposes for which we will use your personal data" above.

Justification: Contract performance, legitimate interest, (to allow our Service providers to provide the necessary services).

1. If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets.
   
   Justification: Legitimate interest (to sell our business or assets); and where required by applicable law, consent (for sensitive personal data).

2. If Liberty International Ltd or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets.
   
   
   Justification: Legitimate interest (to sell our business or assets); and where required by applicable law, consent (for sensitive personal data).

3. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Liberty International Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
   
   ‍Justification: Legal obligation, vital interest.

4. Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or accurate information is provided and fraud is identified or suspected, details may be passed to fraud prevent agencies.
   
   ‍Justification: Legitimate interest (to assist with the prevention of fraud and to assess your risk profile).

5. As a Renter we will share your following personal information with Letting Agents and Landlords: name, email address, previous and current addresses (up to three years), and nationality
   
   As a Landlord we will share your following personal information with Renters and Letting Agents: name, email address, bank account information for payments.
   
   Justification: Consent

 

Change of purpose

We will only use your personal data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If We need to use your personal data for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so.

Please note that We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

6. Your Legal Rights

Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised

 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

 

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;

(b) where our use of the data is unlawful, but you do not want us to erase it;

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

7. CONTACT

Questions, comments and requests regarding this privacy policy are welcome and should be addressed to rentbureau.info@gmail.com.

For the purpose of the relevant data protection legislation, the data controller is Liberty International Ltd

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8. COOKIES

Liberty International Ltd uses cookies to distinguish you from other users. This helps us provide you with a good experience when you use our website, and also allows us to improve our Services. Please note that it is possible to disable cookies being stored on your computer by changing your browser settings. However, our website may not perform properly, or some features may not be available to you if you disable cookies.

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9. RENTAL EXCHANGE NOTICE FOR PRIVACY POLICY

 

Not only will we be able to work with you more closely to manage your existing tenancy agreement, your track record as a tenant will enable Experian to use the information supplied to them to assist other landlords and organisations to:

 

• assess and manage any new tenancy agreements you may enter into;

• assess your financial standing to provide you with suitable products and services;

• manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;

• contact you in relation to any accounts you may have and recovering debts that you may owe;

• verifying your identity, age and address, to help other organisations make decisions about the services they offer;

• help to prevent crime, fraud and money laundering;

• screen marketing offers to make sure they are appropriate to your circumstances;

• for Experian to undertake statistical analysis, analytics and profiling,

• and for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.

 

If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided in this link: www.experian.co.uk/crain (Credit Reference Agency Information Notice (CRAIN)). (For a paper copy, please get in touch with us or with Experian using the contact details in this letter).